An Overview of Accreditation of Higher
Education in the United States
Alexandra Hegji
Analyst in Social Policy
December 12, 2014
Congressional Research Service
7-5700
www.crs.gov
R43826
An Overview of Accreditation of Higher Education in the United States
Summary
Title IV of the Higher Education Act (HEA) authorizes programs that provide financial assistance
to students to assist them in obtaining a postsecondary education at certain institutions of higher
education (IHEs). IHEs wishing to participate in Title IV federal student aid (FSA) programs
must meet several requirements, including being accredited by an agency recognized by the
Department of Education (ED) as a reliable authority on the quality of the education being
offered.
There are three general types of accrediting agencies, each of which serves a specific purpose.
Regional accrediting agencies operate in six regions of the United States and concentrate their
reviews on IHEs within specific regions of the country. National accrediting agencies operate
across the United States and review institutions with a common theme (e.g., religiously affiliated
institutions). Finally, programmatic accrediting agencies operate nationwide and review programs
and single-purpose institutions.
The accreditation process is voluntary and must be requested by educational institutions or
programs. While accrediting agencies’ review processes are guided, in part, by federal
requirements, specific procedures for reviews are adopted by the individual agencies and vary
among them. In general, however, the review process begins with an institutional self-assessment,
then an institution is reviewed by an outside team of peers primarily composed of higher
education faculty and practitioners, and finally, a comprehensive report is submitted by the team
of peers to the accrediting agency, which then makes an accreditation determination.
Although the federal government relies on accrediting agencies to evaluate the quality of
education offered at IHEs, the HEA and ED regulations provide a variety of requirements that
accrediting agencies must meet to be recognized by ED. Key provisions require that accrediting
agencies:
• meet general membership requirements (e.g., agencies must have a voluntary
membership of IHEs);
• consistently apply and enforce standards that ensure the education programs,
training, or courses of study offered are of sufficient quality to meet the stated
objective for which they are offered;
• use review standards that assess student achievement in relation to the
institution’s mission, including, as applicable, course completion, passage of state
licensing examinations, and job placement rates;
• evaluate, among other considerations, an institution’s or program’s curricula,
faculty, facilities, and fiscal and administrative capacity; and
• meet due process requirements with respect to the institutions and programs they
accredit.
Congress may wish to focus on several issues related to accreditation as it considers HEA
reauthorization. These issues may include further development of institutional quality measures,
the potential to restructure or streamline the accreditation system, accreditation’s role in the
changing higher education landscape, and transparency and potential conflicts of interest in the
accreditation process.
Congressional Research Service
An Overview of Accreditation of Higher Education in the United States
Contents
Background ...................................................................................................................................... 1
Historical Role of Accreditation in Higher Education ............................................................... 1
Purpose of Accreditation in Higher Education .......................................................................... 1
Accrediting Agencies ....................................................................................................................... 3
Regional Accrediting Agencies ................................................................................................. 3
National Accrediting Agencies .................................................................................................. 4
Specialized or Programmatic Accrediting Agencies .................................................................. 4
The Accreditation Process ............................................................................................................... 5
Funding ...................................................................................................................................... 5
Evaluations and Review Procedures .......................................................................................... 5
Formal Actions Taken by Accrediting Organizations ................................................................ 7
The Federal Role in Accreditation ................................................................................................... 8
Early Recognition ...................................................................................................................... 8
Higher Education Act of 1965 ................................................................................................... 9
Role of the U.S. Department of Education in Accreditation ..................................................... 9
Evolution of Federal Requirements for Accrediting Agency Recognition .......................... 9
Current Federal Requirements .......................................................................................... 11
2010 Regulations ............................................................................................................... 13
Process for Recognition .................................................................................................... 13
ED-Recognized Accrediting Agencies .................................................................................... 14
For Title IV Purposes ........................................................................................................ 14
Distance Education ............................................................................................................ 14
National Advisory Committee on Institutional Quality and Integrity (NACIQI) .................... 15
Establishment in HEA ....................................................................................................... 15
Mission .............................................................................................................................. 15
Process ............................................................................................................................... 16
Current Members............................................................................................................... 16
Issues for Consideration................................................................................................................. 18
Quality Measures ..................................................................................................................... 18
Institutional Accreditation ................................................................................................. 18
Programmatic Accreditation .............................................................................................. 20
Restructure or Streamline Accreditation .................................................................................. 20
Restructure the Accreditation System ............................................................................... 21
Streamline the Accreditation Agency Recognition Process .............................................. 21
The Changing Postsecondary Education Landscape ............................................................... 22
Competency-Based Programs ........................................................................................... 22
Online Education Providers and Credentials ..................................................................... 23
Other Potential Considerations ................................................................................................ 25
Transparency ..................................................................................................................... 25
Conflicts of Interest ........................................................................................................... 25
Tables
Table 1. Recognized Regional Accrediting Agencies ...................................................................... 3
Congressional Research Service
An Overview of Accreditation of Higher Education in the United States
Table 2. Recognized National Accrediting Agencies ....................................................................... 4
Table 3. Accreditation Actions Taken by ED- and CHEA-Recognized
Accrediting Agencies .................................................................................................................... 7
Contacts
Author Contact Information........................................................................................................... 26
Congressional Research Service
An Overview of Accreditation of Higher Education in the United States
Background
Historical Role of Accreditation in Higher Education
Historically, accreditation in higher education developed as a part of the evolution of the
American higher education system, at a time when it was becoming problematic that no single
point of control or central body existed to set educational standards. In the late 19th century, there
was no consensus on the content of the educational programs offered by postsecondary
educational institutions or the distinctions between educational offerings at secondary and
postsecondary institutions. Because the boundaries were unclear, the first voluntary association of
postsecondary institutions was formed in 1895 to define the difference between high school and
college and to develop some guidelines and procedures for peer review as a condition for
membership.
Over time, a number of regional associations formed whose membership was contingent on
accreditation. The associations established separate accrediting bodies or commissions that were
responsible for developing standards and passing on the institutional qualifications for
membership. By the early 1970s, all but a small percentage of the degree-granting institutions of
higher education were either accredited or applicants for accreditation.
Purpose of Accreditation in Higher Education
The United States does not have a centralized authority exercising singular national control over
postsecondary educational institutions. The states assume varying degrees of control over
education, but in general, institutions of higher education (IHEs) are permitted to operate with
considerable independence and autonomy. Consequently, the character and quality of IHEs’
programs can vary widely. The role of accreditation in higher education, therefore, is to help
ensure a level of acceptable quality across the wide array of programs and institutions in higher
education.
The U.S. Department of Education (ED) describes the practice of accreditation as “a means of
conducting nongovernmental, peer evaluation of educational institutions and programs” and lists
the following as some of the purposes of accreditation:
• verify that an institution or program meets established standards;
• assist prospective students in identifying acceptable institutions;
• assist institutions in determining the acceptability of transfer credits;
• help to identify institutions and programs for the investment of public and private
funds;
• protect an institution against harmful internal and external pressure;
• create goals for self-improvement of weaker programs and stimulate a general
raising of standards among educational institutions;
• involve the faculty and staff comprehensively in institutional evaluation and
planning;
Congressional Research Service
1
An Overview of Accreditation of Higher Education in the United States
• establish criteria for professional certification and licensure and for upgrading
courses offering such preparation; and
• provide one of several considerations used as a basis for determining eligibility
for federal assistance.1
The Council for Higher Education Accreditation (CHEA)—a membership organization currently
made up of approximately 3,000 colleges and degree-granting universities, and the primary
nongovernmental higher education organization that scrutinizes the quality of higher education
accrediting agencies—alternatively describes accreditation as “a process of external quality
review created and used by higher education to scrutinize colleges, universities, and programs for
quality assurance and quality improvement.”2 CHEA specifically identifies the following roles or
purposes of accreditation:
• Assure quality. Accreditation is the primary means by which colleges,
universities, and programs assure quality to students and the public. Accredited
status is a signal to students and the public that an institution or program meets
minimum threshold standards for its faculty, curriculum, student services, and
libraries, among other elements. Accredited status is conveyed only if institutions
and programs provide evidence of fiscal stability.
• Provide access to federal and state funds. Accreditation is required for access
to federal funds, such as student aid and other federal programs. Federal student
aid funds are available to students only if the institution or program they are
attending is accredited by an ED-recognized accrediting organization. State funds
to institutions and students are generally contingent on accredited status.3
• Engender private sector confidence. Accreditation status of an institution or
program is important to employers when evaluating credentials of job applicants
and when deciding whether to provide aid support for current employees seeking
additional education. Private individuals and foundations look for evidence of
accreditation when making decisions about private giving.
• Facilitate ease of transfer of credits. Accreditation is important to students for
smooth transfer of courses and programs among colleges and universities.
Receiving institutions take note of whether the credits a student wishes to transfer
have been earned at an accredited institution and, in some instances, which
agency accredited the institution.4
1 See U.S. Department of Education, “Accreditation in the United States,” http://www2.ed.gov/admins/finaid/accred/
accreditation_pg2.html#U.S.
2 Much of this section was adapted from An Overview of U.S. Accreditation by Judith S. Eaton, CHEA, Washington,
DC, Revised August 2012, http://www.chea.org/pdf/Overview%20of%20US%20Accreditation%202012.pdf
(hereinafter CHEA, Overview of Accreditation).
3 For more information on how states use accreditation status in decisions to authorize postsecondary institutions, see
State Uses of Accreditation: Results of a Fifty-State Survey, by P. Ewell, M. Boeke, and S. Zis at the National Center
for Higher Education Management Systems, http://www.nchems.org/c2sp/documents/CHEAStateStudy_2010.pdf.
4 Prior to the enactment of the Higher Education Opportunity Act of 2008 (HEOA; P.L. 110-315), accrediting agencies
were not required to address transfer of credit policies. See pages12-13 of this report for more information on the
federal requirements regarding transfer of credit policies enacted in the HEOA.
Congressional Research Service
2
An Overview of Accreditation of Higher Education in the United States
Accrediting Agencies
There are three general types of accrediting organizations, or agencies, which are discussed in
detail below. Both ED and CHEA scrutinize accrediting agencies and determine whether they are
reliable authorities as to the quality of education offered. ED recognition is viewed as more
important because IHEs must be accredited by an accrediting agency recognized by ED in order
to participate in student financial assistance programs under Title IV of the HEA or other federal
programs.
Regional Accrediting Agencies
There are currently seven regional accrediting agencies operating in six regions of the United
States.5 These accreditation agencies concentrate on specific regions of the country. Regional
accreditation agencies started as leagues of traditional universities and colleges in particular areas
of the country.6 Accreditation status from regional accrediting agencies is granted to an entire
institution, including all of its programs, for purposes of participating in Title IV FSA programs,
but such status does not guarantee the quality of individual programs or the students who
graduate from those programs. In 2010-2011, these organizations accredited 3,050 institutions,
and all of these institutions are degree granting.7 Table 1 lists the regional accrediting
organizations recognized by ED, CHEA, or both.
Table 1. Recognized Regional Accrediting Agencies
(as of October 2014)
Regional Accrediting Organizations Recognized by the U.S. Department of Education, CHEA, or Both
Middle States Association of Colleges and Schools, Middle States Commission on Higher Education (Both)
New England Association of Schools and Col eges, Commission on Institutions of Higher Education (Both)
North Central Association of Col eges and Schools, The Higher Learning Commission (Both)
Northwest Commission on Col eges and Universities (ED Only)
Southern Association of Colleges and Schools, Commission on Colleges (Both)
Western Association of Schools and Col eges, Accrediting Commission for Senior Col eges and Universities (Both)
Western Association of Schools and Col eges, Accrediting Commission for Community and Junior Col eges (Both)
Source: The Council for Higher Education Accreditation (CHEA), Recognized Accrediting Organizations,
http://www.chea.org/pdf/CHEA_USDE_Al Accred.pdf and the U.S. Department of Education (ED),
“Accreditation in the United States: Regional and National Institutional Accrediting Agencies,”
http://www2.ed.gov/admins/finaid/accred/accreditation_pg6.html#RegionalInstitutional.
5 Unless otherwise noted, the source for this section is CHEA, Fact Sheet #1, August 2012, http://www.chea.org/pdf/
Fact%20Sheet%201%20Revised%202012.pdf (hereinafter CHEA, Fact Sheet #1).
6 Although regional accrediting agencies initially defined their own boundaries, these boundaries have now been
adopted by ED for purposes defining of an accrediting agency’s scope of recognition by ED. For additional information
on an accrediting agency’s scope of recognition, see pp. 14-15 of this report.
7 CHEA, Fact Sheet #1. Regional accrediting may also accredit for-profit institutions, regardless of whether they are
degree-granting institutions, however, this is rare. CHEA, The Fundamentals of Accreditation: What Do You Need to
Know?, September 2002, http://www.chea.org/pdf/fund_accred_20ques_02.pdf.
Congressional Research Service
3
An Overview of Accreditation of Higher Education in the United States
National Accrediting Agencies
These entities operate across the United States and also accredit entire institutions. National
accreditation agencies started as associations of schools with a common theme. Many served
schools that were not initially founded as colleges or universities. There are two types of national
accrediting organizations—faith-based and private career. The four faith-based accreditors review
religiously affiliated or doctrinally based institutions and represent a small percentage of the
institutions accredited by national accrediting organizations (470 institutions). The seven private
career accreditors accredit a substantially larger number of institutions. Of the 4,298 institutions
accredited by private career accreditors in 2010-2011, about 67% are non-degree granting and
about 88% are proprietary institutions. Many are single-purpose institutions (e.g., focused on
business and technology).8 Table 2 lists the national accrediting agencies recognized by ED,
CHEA, or both.
Table 2. Recognized National Accrediting Agencies
(as of October 2014)
National Accrediting Organizations Recognized by the U.S. Department of Education, CHEA, or Both
National Faith-Related Accrediting Organizations
Association for Biblical Higher Education, Commission on Accreditation (Both)
Association of Advanced Rabbinical and Talmudic Schools, Accreditation Commission (Both)
Association of Theological Schools in the United States and Canada, Commission on Accrediting (Both)
Transnational Association of Christian Colleges and Schools, Accreditation Commission (Both)
National Career-Related Accrediting Organizations
Accrediting Bureau of Health Education Schools (ED Only)
Accrediting Commission of Career Schools and Colleges (ED Only)
Accrediting Council for Continuing Education and Training (ED Only)
Accrediting Council for Independent Colleges and Schools (Both)
Council on Occupational Education (ED Only)
Distance Education and Training Council, Accrediting Commission (Both)
National Accrediting Commission of Cosmetology Arts and Sciences, Inc. (ED Only)
Source: The Council for Higher Education Accreditation (CHEA), Recognized Accrediting Organizations,
http://www.chea.org/pdf/CHEA_USDE_Al Accred.pdf and the U.S. Department of Education (ED),
“Accreditation in the United States: Regional and National Institutional Accrediting Agencies,”
http://www2.ed.gov/admins/finaid/accred/accreditation_pg6.html#RegionalInstitutional.
Specialized or Programmatic Accrediting Agencies
These entities also operate nationwide and review programs and single-purpose institutions (e.g.,
engineering and technology). In many instances, particular programs (e.g., law) are accredited by
a specialized accrediting organization, while the institution at which the program is offered is
8 CHEA, Fact Sheet #1.
Congressional Research Service
4
An Overview of Accreditation of Higher Education in the United States
accredited by a regional or national accrediting organization. Programmatic accreditation can
demonstrate that a specific department meets established standards for a certain field of study. For
example, many prospective employers require graduation from a program accredited by a certain
programmatic organization and licensure requirements for some fields in certain states require
recognized programmatic accreditation. Most of the specialized or programmatic accrediting
agencies review units within an IHE that is accredited by one of the regional accrediting agencies;
however, certain accrediting agencies also accredit professional schools and other specialized or
vocational IHEs that are freestanding in their operations. Thus, a specialized or programmatic
accrediting agency may also function in the capacity of an institutional accrediting agency. As of
October 2014, there are approximately 68 programmatic accrediting agencies recognized by
CHEA, ED, or both.9
The Accreditation Process
The accreditation process is voluntary and must be requested by educational institutions or
programs. Accreditation of institutions takes place on a cycle that may range from every few
years to as many as 10 years.10 Accreditation is an ongoing process and the initial earning of
accreditation does not guarantee indefinite accredited status.
Funding
Accrediting organizations are funded primarily by annual dues from IHEs and programs that are
accredited and fees that institutions and programs pay for accreditation reviews. In some cases, an
accrediting organization may receive financial assistance from sponsoring organizations.
Accrediting organizations sometimes obtain funds for special initiatives from government or
private foundations. Funds may also be derived from conferences and meetings. Accrediting
organizations reported they spent more than $114 million in 2010-2011.11 Additionally,
accrediting organizations employed more than 850 paid full- and part-time staff and worked with
more than 20,700 volunteers.12
Evaluations and Review Procedures
To gain accreditation, an institution must be evaluated through a number of steps outlined by the
accrediting organization. These procedures are guided, in part, by the federal requirements
discussed later in this report. However, the specific procedures for evaluation reviews adopted by
accreditation agencies do vary among them.13 The following description of the evaluation process
9 CHEA, Recognized Accrediting Organizations, October 2014, http://www.chea.org/pdf/
CHEA_USDE_AllAccred.pdf.
10 Some opponents of the accreditation process claim that current accreditation cycles are too long and fail to account
for changes in institutional quality over shorter periods of time.
11 CHEA, Overview of Accreditation.
12 Ibid.
13 The major work products of an accreditation review, such as the self-study, team report, and other official
communications between the accrediting agency and the institution are generally kept confidential. Accrediting
agencies are required under federal law to provide the public, the Secretary, and state licensing agencies a summary of
any review resulting in a final accreditation decision involving denial, termination, or suspension of accreditation,
(continued...)
Congressional Research Service
5
An Overview of Accreditation of Higher Education in the United States
is intended to provide a general overview of how institutions are evaluated for initial or renewal
accreditation status.
The process typically begins with institutional self-assessment. This self-study is designed to be
an examination of whether an institution’s operation and performance meet the basic
requirements or standards of the accrediting organization (which differ somewhat from
organization to organization). The self-study typically involves the preparation of detailed written
reports showing how the institution or program determines whether it meets or exceeds the
agency’s standards, as well as how it plans to improve in the future.
The next phase in the evaluation process typically involves a peer review and site visit at the
institution. Peer review is conducted by an outside team primarily composed of higher education
faculty and administrators. These peers review the self-study and serve on visiting teams, which
also include practitioners in specific fields and members of the public (non-academics who have
an interest in higher education). After analyzing the self-study, the visiting team conducts a site
visit to determine whether the standards of the accrediting organization are being met; the self-
study analysis provides the basis for scrutiny by the team during the visit to the campus. During
the visit, team members have an opportunity to talk to faculty, students, staff, and administrators
about issues and questions arising from the self-study. The team usually conducts an exit
interview with the president or dean to discuss issues that have surfaced during the review. All
team members are volunteers and are generally not compensated.
Following the visit to an institution, the team typically prepares a comprehensive accreditation
report that includes judgments about the institution’s or program’s strengths, weaknesses, and
potential for improvement. Staff of the accrediting organization may meet with the visiting review
team to discuss the draft report. The final report is submitted to the accreditation agency, with
recommendations about which actions should be taken.
Based on the results of the self-assessment, peer review, and site visit, the decision-making bodies
of accrediting organizations (commissions) determine whether accreditation should be awarded to
a new institution, renewed for an existing institution, denied, or put on provisional or
probationary status. All accreditation agencies have an appeals process and some requirements
are determined by federal law.14
Accrediting agencies also monitor institutions and programs between reviews and may require
annual reporting, interim reviews, or substantive change reports from the institutions and
programs they have accredited. Annual reporting could include financial statements and updated
curricular or planning information. Interim reviews are required when issues are left unresolved
from a comprehensive evaluation.
According to CHEA, accreditation is “a trust-based, standards-based, evidence-based, judgment-
based, peer-based process.”15 Over the years, the accreditation process has come under scrutiny
amid calls for reform. Some critics argue the accreditation process places too much emphasis on
(...continued)
together with the comments of the affected institution.
14 See page 13 of this report for more information on federal due process requirements.
15 CHEA, Overview of Accreditation.
Congressional Research Service
6
An Overview of Accreditation of Higher Education in the United States
inputs rather than outputs.16 Others say accreditation only demonstrates that an institution is
following what the accrediting body believes is the appropriate formula for a successful
educational institution, not that it is in fact a successful institution.17
Formal Actions Taken by Accrediting Organizations
Accrediting agencies take a range of formal actions following evaluations and reviews at
institutions or of programs for initial or continuing accreditation. Table 3 below highlights the
types and frequency of actions reported by accrediting agencies to CHEA in 2013,18 displayed by
type of organization. It is important to note that accrediting agencies do not use a common set of
definitions for the actions displayed below, so some actions are categorized by their relevancy to
more commonly defined actions.
Table 3. Accreditation Actions Taken by ED- and CHEA-Recognized
Accrediting Agencies
January 1, 2013-December 1, 2013
National
National Faith-
Career-
Regional
Related
Related
Programmatic
Accreditation
Accrediting
Accrediting
Accrediting
Accrediting
Action
Agencies
Agencies
Agencies
Agencies
Totals
Grant
20 11 246 745
1,022
Accreditation
Reaffirm
400
18 887
1,545
2,850
Accreditation
Deny
2 1 31 42 76
Accreditation
Withdraw
9 8 82
100
199
Accreditation
Defer
6 10 229 240 485
Accreditation
Show Cause or
31
7 186 144 368
Probation Ordera
Notice or
25 6 0 85
116
Warningb
16 For example, in September 2006, the Secretary of Education’s Commission on the Future of Higher Education made
several recommendations regarding changes to the accreditation process. One of the key recommendations was that
accrediting agencies should make performance outcomes the priority over measures of inputs or process. For more
information, see A Test of Leadership: Charting the Future of U.S. Higher Education. Available online at
http://www.ed.gov/about/bdscomm/list/hiedfuture/reports/final-report.pdf.
17 George C. Leef and Roxana D. Burris, Can College Accreditation Live Up to Its Promise?, American Council of
Trustees and Alumni, Washington, DC, July 20002, p. 18.
18 This is the most recent publication of The Condition of Accreditation found on CHEA’s website (2012 Edition).
Congressional Research Service
7
An Overview of Accreditation of Higher Education in the United States
National
National Faith-
Career-
Regional
Related
Related
Programmatic
Accreditation
Accrediting
Accrediting
Accrediting
Accrediting
Action
Agencies
Agencies
Agencies
Agencies
Totals
Actions Under
0 0 1 0 1
Appeal
Totals
493
61
1,662
2,901
5,117
Source: CHEA Almanac Online, “Update: Accreditation Actions,” http://www.chea.org/Almanac%20Online/
index.asp.
Notes: The terms used here are meant to provide general descriptions of the types of actions taken by
accrediting agencies, as accrediting agencies’ definitions for these terms may vary. Additionally, some accrediting
agencies may use additional types of actions that are not included in this table.
a. Show cause and probation orders are both “determination[s] that accreditation requirements have not
been met and the accreditor mandates corrective action to resolve one or more deficiencies within a
specified period of time.” However under show cause, in general, the accrediting agency requires the
institution to “show cause” why an action should not be taken.
b. Notice/warning is a “determination that although one or more accreditation requirements have not been
met, the institution has the capacity to make appropriate improvements within a reasonable period of time
and fully meet accreditation standards for the long term.”
The Federal Role in Accreditation
Early Recognition
Federal recognition of accrediting agencies was initiated in 1952, shortly after the passage of the
Veterans’ Readjustment Assistance Act of 1952 (the Korean GI Bill; P.L.82-550), to assess higher
education quality and link it to determining which institutions would qualify to receive federal aid
under the GI Bill. Rather than creating its own system of quality assurance, the federal
government opted to rely on existing accrediting agencies and assumed accreditation agencies
were reliable indicators of educational quality. A recognition process was established in the (then)
Office of the U.S. Commissioner of Education to produce a list of federally recognized
accrediting agencies and associations.19
The National Defense Education Act of 1958 (NDEA; P.L. 85-864) also addressed the federal role
in accreditation of higher education. In defining the term “institution of higher education” for the
purposes of identifying institutions eligible to receive federal funds to assist in making low-
interest loans to postsecondary students in need,20 the NDEA maintained the criterion that
institutions be accredited by an agency or association recognized by the U.S. Commissioner of
Education.
19 For an in-depth look at how the federal role in accreditation evolved, see Proffit, John R. 1979. The Federal
Connection for Accreditation. JSTOR. The Journal of Higher Education. http://www.jstor.org/stable/1980935?seq=1
(accessed November 14, 2014).
20 This program was known as the National Defense Student Loan Program (NDSL), the precursor to the federal
Perkins Loan program.
Congressional Research Service
8
An Overview of Accreditation of Higher Education in the United States
Higher Education Act of 1965
In 1965, the importance of the accrediting agencies was augmented further with the enactment of
the Higher Education Act (HEA; P.L. 89-329). Title IV of the HEA created new federal student
aid programs for non-veterans, and only accredited institutions recognized by the (then) Office of
the U.S. Commissioner of Education were eligible to receive these funds.21 As a result, non-
accredited institutions stood to lose access to billions of dollars in federal funds; thus, achieving
and maintaining an accredited status became almost essential for the financial survival of some, if
not most, institutions and programs.
Role of the U.S. Department of Education in Accreditation
ED does not accredit IHEs or programs of higher education. Its primary role is to recognize,
through the process and conditions set forth in Section 496 of the HEA and Title 34 of the Code
of Federal Regulations (C.F.R.), Part 602, an accrediting agency or association as “a reliable
authority as to the quality of education or training offered” at IHEs for the purposes of Title IV
funding and other federal programs.22 As part of the recognition process, the accreditation agency
must show that it is “effective in its performance” with respect to the criteria established in the
law and regulations. Recognition may be revoked at any time if ED determines the agency has
become ineffective in its performance.
The Accrediting Agency Evaluation Unit (AAEU) was established within ED to help facilitate
accreditation matters.23 In effect, the AAEU carries out the statutory and regulatory requirements
of ED as they relate to the application and approval of accrediting agencies. One of its primary
functions is “to conduct a continuous review of standards, policies, procedures, and issues in the
area of ED’s interests and responsibilities relative to accreditation.”
Evolution of Federal Requirements for Accrediting Agency Recognition
Section 496 of the HEA sets forth the standards and criteria accrediting agencies must meet to be
recognized by ED as reliable authorities as to the quality of education offered at IHEs. Between
the 1965 enactment of the HEA and its reauthorization in 1992, accrediting agencies were
required to be recognized by ED for Title IV purposes, but the HEA specified few, if any, criteria
for ED recognition.
21 Accreditation currently serves as one of the three aspects of the program integrity triad intended to provide balance in
assuring the eligibility of institutions for Title IV purposes. The other two legs include state authorization and
certification by ED. The federal government historically has relied on these approaches to avoid generating concerns
about federal interference in educational decision-making.
22 ED also recognizes state agencies for the approval of public postsecondary vocational education and nurse education.
The criteria and procedures used by the Secretary in designating a state agency as a reliable authority concerning the
quality of public postsecondary vocational education in a state are contained in Part 603 of Title 34 of the Code of
Federal Regulations (CFR). The criteria and procedures used by the Secretary in designating a state agency as a reliable
authority concerning the quality of training offered by schools of nursing in a state are contained in regulations
published in the January 16, 1969 Federal Register. For more information, see U.S. Department of Education,
“Accreditation in the United States, Criteria for Recognition of States Agencies for Vocational Education,”
http://www2.ed.gov/admins/finaid/accred/accreditation_pg17.html#StateAgenciesforVocationalEducation.
23 See U.S. Department of Education, “Accreditation in the United States, The Accrediting Agency Evaluation Unit,”
http://www2.ed.gov/admins/finaid/accred/accreditation_pg3.html.
Congressional Research Service
9
An Overview of Accreditation of Higher Education in the United States
Leading up to the 1992 reauthorization of the HEA, concerns about fraud and abuse in the
accreditation process by the proprietary school sector were evident.24 Rather than singling out the
proprietary institutions for special oversight, Congress opted to strengthen the criteria for ED
recognition of accrediting agencies of all types of institutions.25 Thus, HEA Section 496 was
added in the Higher Education Amendments of 1992 (P.L. 102-325) in an effort to require
accrediting agencies to exercise genuine oversight of the schools they accredited. The new
Section 496 described the types of organizations eligible for ED recognition (e.g., state, regional,
or national agencies with voluntary memberships). It also detailed the types of school assessment
standards—such as recruitment and admissions practices; program length; and “success with
respect to student achievement in relation to [the school’s] mission,” which could include
consideration of course completion, state licensing examinations, and job placement rates—that
agencies were to apply consistently to all IHEs.26
The 1998 reauthorization (the Higher Education Amendments of 1998; P.L. 105-244) saw
changes in the scope of the criteria for ED recognition of accrediting agencies, especially in
regard to changing education delivery methods and distance education programs. Specifically, the
act permitted the Secretary of Education (Secretary) to include within an accrediting agency’s
scope of recognition the ability to assess an IHE’s distance education programs. In doing so,
Congress sought to ensure that the federal government was providing Title IV support only to
quality programs in the rapidly growing area of distance education.27
Congress provided a host of additional criteria for ED recognition of accrediting agencies in the
Higher Education Opportunity Act of 2008 (HEOA; P.L. 110-315). The 2008 additions included
provisions relating to how accrediting agencies were to review distance education programs;
transparency of agency policies and decision-making processes; due process requirements for
IHEs subject to an adverse agency action; and various other standards related to IHE operations,
including ensuring that IHEs make transfer-of-credit policies publicly available and submit teach-
out plans to accrediting agencies in specified circumstances.28
24 For instance, some Members of Congress were particularly concerned about the close relationship between the
proprietary school trade associations and their respective accrediting bodies.
25 For additional information on the Higher Education Amendments of 1992 as they relate to institutional eligibility, see
CRS Report 93-861, Institutional Eligibility: The Higher Education Amendments of 1992, by Margot A. Schenet,
archived, available upon request.
26 Federal regulations related to ED recognition of accrediting agencies were in effect prior to 1992. The most recent
regulations published immediately before the legislative enactment of ED-recognition criteria contained many of the
same concepts that were eventually codified in the 1992 amendments (e.g., evaluation of school assessment standards,
including student achievement, and applying review criteria consistently to all IHEs). See Department of Education,
“Secretary’s Procedures and Criteria for Recognition of Accrediting Agencies,” 53 Federal Register 25088, July 1,
1988.
27 See, for example, U.S. Congress, House Committee on Education and the Workforce, Higher Education
Amendments of 1998, report to accompany H.R. 6, 105th Cong., April 17, 1998, H.Rept. 105-481 (Washington: GPO,
1998), p. 148.
28 A teach-out plan is a written plan developed by an institution that provides for the equitable treatment of its own
students if an institution, or an institutional location that provides 100% of at least one program, ceases to operate
before all students have completed their program of study, and may include, if required by the institution’s accrediting
agency, a teach-out agreement between institutions.
Congressional Research Service
10
An Overview of Accreditation of Higher Education in the United States
Current Federal Requirements
Today, many of the ED-recognition requirements put into place since 1992 remain. According to
Section 496 of the HEA, an accrediting agency must be a state, regional, or national agency or
association that demonstrates the ability and expertise to serve as an accrediting agency or
association. These agencies or associations must then meet one of the following specific criteria:
• For the purpose of determining eligibility for Title IV programs, the agency or
association must have a voluntary membership of IHEs and have the
accreditation of these institutions as one of its primary purposes; or, for the
purposes of participation in other ED or federal programs, the agency must have
a voluntary membership and have its primary purpose be accrediting IHEs or
programs.
• It must be a state agency approved by the Secretary as an accrediting agency or
association on or before October 1, 1991.29
• For the purpose of determining eligibility for Title IV programs, the agency or
association must either conduct accreditation through a voluntary membership
organization of individuals participating in a profession, or the agency or
association must have as its primary purpose accrediting programs within
institutions that have already been accredited by another agency or association
recognized by the Secretary.
Accrediting agencies or associations meeting the first or third criterion must also be
administratively and financially separate and independent30 from any associated or affiliated trade
organization or membership organization. For accrediting organizations meeting the third
criterion, if the agency or association was recognized by the Secretary on or before October 1,
1991, the Secretary may waive the requirement that the agency or association be administratively
and financially separate and independent if it can be shown that existing relationships with
associated or affiliated trade organizations or membership organizations have not compromised
the independence of the accreditation process.
Regardless of the type of accrediting association or agency, the organization must consistently
apply and enforce standards that ensure that the education programs, training, or courses of study
offered by an IHE are of sufficient quality to meet the stated objectives for which they are
offered. The standards used by the accrediting agency or association must assess student
achievement31 in relation to the institution’s mission, including, as applicable, course completion,
passage of state licensing examinations, and job placement rates.
29 The New York State Board of Regents and Commissioner of Education is the only such state agency in existence.
30 Section 496 (b) defines “separate and independent” to mean that (1) members of the postsecondary education
governing body of the accrediting agency or association are not selected or elected by the board or chief executive
officer of any related, associated, or affiliated trade associations or membership organizations; (2) the board must have
at least one public member for every six board members; (3) dues paid to the accrediting agency or association must be
separate payments from any dues paid to any related, associated, or affiliated trade associations or membership
organizations; and (4) the accrediting agency or association develops and determines its own budget without consulting
any other entity or organization.
31 Institutions set their own standards for student achievement, and accrediting agencies, with their members, set
student achievement standards for their individual organizations. Section 496(a)(5)(A) of the HEA explicitly states that
success with respect to student achievement may include different standards for different institutions or programs, as
established by the institution.
Congressional Research Service
11
An Overview of Accreditation of Higher Education in the United States
The accrediting organization must consider the institution’s curricula, faculty, facilities, fiscal and
administrative capacity, student support services, recruitment and admissions practices, measures
of program length, objectives of the credentials offered, and student complaints received directly
by the agency or association or those that are available to the agency or association.32 The
institution’s record of compliance with the institutional requirements of Title IV must also be
examined with respect to the most recent student loan default rate data provided by ED, the
results of financial or compliance audits, program reviews, and other information provided to the
agency or association by ED.
Accrediting organizations must confirm that the institutions or programs they accredit (1) have
transfer of credit policies; (2) make transfer of credit policies public; and (3) make public the
criteria by which an institution makes a determination with regard to accepting credits from
another institution.33
Under Section 496(a)(6) of the HEA, accrediting agencies recognized by ED must meet certain
requirements with respect to due process. That is, an accrediting agency is required to implement
specific procedures to resolve disputes between the accrediting agency and any institution that is
subject to the accreditation process. Under current law, accrediting agencies are required to
provide an IHE or program with, at minimum, the following:
• adequate written specification of requirements and deficiencies at the IHE or
program being examined;
• sufficient opportunity to provide a written response to any deficiencies prior to
final evaluation and withdrawal proceedings;
• the opportunity to have a hearing;
• the right to appeal any adverse action against it; and
• the right to be represented by counsel.34
Accrediting agencies and associations must meet additional requirements that focus on operating
procedures, including reviewing newly established branch campuses at accredited institutions and
publicly disclosing when an institution is considered for accreditation or reaccreditation.
Accrediting agencies and associations must also perform regular onsite inspections that focus on
educational quality and program effectiveness.35 Additionally, accrediting agencies must
monitor36 the expansion of programs at institutions that are experiencing significant enrollment
growth and must require institutions to submit a teach-out plan in certain circumstances.37
32 As part of an accrediting agency’s administrative and fiscal responsibilities under federal laws and regulations, its
accreditation teams must include competent and knowledgeable individuals, qualified by education and experience in
their own right and trained by the agency on their responsibilities, as appropriate for their roles, regarding the agency’s
standards, policies, and procedures to conduct on-site evaluations.
33 These requirements were enacted in the HEOA.
34 Accrediting agencies may provide additional procedures beyond the statutory minimum if they choose.
35 Prior to the 1998 HEA amendments, accrediting agencies were required to make unannounced visits to institutions.
Unannounced visits are no longer required but are permitted in section 496(c)(1) of the HEA.
36 Such monitoring includes the identification of problems with an institution’s continued compliance with
accreditation standards that takes into account the strength and stability of institutions and programs. Reevaluation of
programs must include periodic reports and collection and analysis of key data and indicators, identified by the
accreditor, including but not limited to, fiscal information and measures of “student success” as defined by the
(continued...)
Congressional Research Service
12
An Overview of Accreditation of Higher Education in the United States
Accrediting agencies are required to notify ED, state licensing or authorizing agencies, and other
appropriate accrediting organizations of adverse accrediting decisions38 at the same time the
institution or program being evaluated is notified of the decision. Accrediting organizations must
provide the aforementioned parties and the public with a statement summarizing the reasons for
the adverse decision, along with evidence that the affected institution has been offered an
opportunity to provide official comment.39
2010 Regulations
In a Federal Register dated October 29, 2010,40 ED published amended regulations pertaining to
the eligibility of IHEs to participate in Title IV programs under the HEA. Among these amended
regulations was a new requirement, effective July 1, 2011, that accrediting agencies review an
institution’s policies and procedures for determining credit hours and the application of those
policies and procedures to programs and coursework in accordance with a new federal definition
of a credit hour41 for the purposes of Title IV aid eligibility.42
Process for Recognition
Like the standards and criteria an accrediting agency must meet to be recognized by ED, the
process for ED recognition was not established in the HEA until the 1992 reauthorization. At that
time, Congress prescribed the major components of the recognition process, which largely have
gone unchanged since that time. The Section 496 procedures for recognition include requirements
to conduct independent evaluations. These independent evaluations are to include (1) the
solicitation of third party information related to the performance of the accrediting agency; (2)
site visits, including, as appropriate, unannounced site visits to accrediting agencies; and (3) at the
discretion of the Secretary,43 site visits to representative member institutions. Other requirements
specified in Section 496 include the requirement for ED to make records of the decision-making
(...continued)
institution.
37 An institution is required to submit a teach-out plan in the event of any of the following: (1) ED notifies the
accrediting agency of any emergency or initiated a limitation, suspension, or termination action against the institution;
(2) the accrediting agency acts to withdraw, terminate, or suspend the accreditation of the institution; and (3) the
institution notifies the accrediting agency that the institution intends to cease operations.
38 Adverse accrediting decisions include final denial, withdrawal, suspension, or termination of accreditation or
placement on probation of an institution, together with any adverse action with respect to an institution.
39 Prior to the enactment of the HEOA, accrediting agencies were required to provide information to the public and
federal government “upon request.” The HEOA makes the “summary” of actions a requirement.
40 For more information see U.S. Department of Education, “Negotiated Rulemaking for Higher Education 2009-2010,
Team 1—Program Integrity,” http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html.
41 According to ED, the new credit-hour definition in 34 CFR Section 600.2 is intended to establish a quantifiable,
minimum basis for a credit hour that, by law, is used in determining eligibility for, and the amount of, federal program
funds that a student or institution may receive. Accrediting agencies recognized by ED for the purposes of Title IV aid
eligibility are required to use the definition in 34 CFR Section 600.2 for federal program purposes such as determining
institutional eligibility, program eligibility, and student enrollment status and eligibility.
42 34 CFR Section 602.24(f) is the basis for this requirement; this section of the CFR also provides the conditions
necessary for accrediting agencies to meet this requirement.
43 The statutory language relating to accreditation primarily references the Secretary of Education when outlining
federal requirements. In this report, references to the Secretary of Education and U.S. Department of Education are
used interchangeably.
Congressional Research Service
13
An Overview of Accreditation of Higher Education in the United States
process available and to publish reasons for denial of recognition. ED is specifically prohibited
from basing recognition decisions on anything other than the statutory criteria, while accrediting
agencies are expressly permitted to have criteria in addition to those needed for recognition.
Once granted, recognition is established for up to five years. The accrediting organization must
then be reapproved for inclusion on the list of recognized accrediting entities.
ED-Recognized Accrediting Agencies
ED recognizes agencies that accredit all types of institutions (public, private nonprofit, and
proprietary) and a variety of educational programs. They include agencies that accredit multi-
disciplined universities, as well as those that accredit smaller, specialized institutions or a specific
program within an institution.44 ED publishes lists of recognized accrediting agencies in certain
categories that may be used by institutions to seek accreditation or by students to ensure a
reasonable assurance of program quality and acceptance of diplomas and degrees by employers.
Two of these categories are discussed below.
For Title IV Purposes
As of November 2014, ED recognizes 37 accrediting agencies for Title IV purposes. These
agencies include national, regional, and programmatic accrediting organizations.45 Institutions
may apply to these accrediting agencies to establish eligibility to participate in Title IV programs
under the HEA.
Distance Education
Distance education programs46 must be evaluated by an accrediting agency recognized by ED as
having the evaluation of distance education programs within its scope of recognition.47
Accrediting agencies that accredit distance education programs are not required to have separate
44 Generally, institutions are accredited by only one accrediting agency or association. Dually accredited institutions
must choose one accrediting agency for the purposes of Title IV eligibility.
45 ED places some conditions and limitations on the types of institutions that may be accredited for Title IV purposes at
accrediting agencies that specialize in programmatic accreditation. For a list of the 37 accrediting agencies and any
conditions that may apply, see U.S. Department of Education, “Accreditation in the United States, Accrediting
Agencies Recognized for Title IV Purposes,” http://www2.ed.gov/admins/finaid/accred/
accreditation_pg9.html#TitleIVRecognition.
46 On July 1, 2010, regulations issued by ED came into effect, distinguishing distance education from correspondence
education. In general, correspondence education is provided through one or more home study courses by an institution
to students who are separated from the instructor whereby interaction between the instructor and student is limited, not
regular and substantive, and is primarily initiated by the student. Accrediting organizations are required to consider
correspondence education as separate and distinct from distance education as it relates to accreditation,
preaccreditation, and expansion of scope.
47 An accrediting agency that has been reviewed since the new distance education and correspondence education
regulations came into effect is required to demonstrate its evaluation of distance education and/or its evaluation of
correspondence education in order to retain distance education and/or correspondence education in its scope of
recognition. Agencies that have not yet been reviewed for renewal of recognition and that previously had distance
education within their scope of recognition are recognized for both distance education and correspondence education.
That status may change upon their next review. Currently 8 accrediting agencies were recognized for distance
education prior to the new definitions and have yet to undergo a recognition review.
Congressional Research Service
14
An Overview of Accreditation of Higher Education in the United States
standards, procedures, or policies for the evaluation of distance education. They are, however,
required to ensure that institutions track the identity of students who participate in distance
education or correspondence education offerings while protecting students’ privacy and notifying
students of any additional costs associated with such verifications. As of November 2014, ED
recognizes 32 accrediting agencies for distance education purposes.48
National Advisory Committee on Institutional Quality and
Integrity (NACIQI)
Establishment in HEA
NACIQI advises the Secretary on matters related to accreditation, including decisions to
recognize accrediting organizations. Section 114 of the HEA provides for the establishment of
NACIQI, along with the qualifications for membership, meeting procedures, and other reporting
requirements. NACIQI was originally established under the HEA under the 1992 Amendments to
the Higher Education Act (P.L. 102-325).49
In 2008, the HEOA amended the structure of NACIQI. Prior to enactment of the HEOA, NACIQI
consisted of a 15-member committee appointed solely by the Secretary. Under the HEOA,
NACIQI was expanded to an 18-member committee, with 6 appointments made by the Speaker
of the U.S. House of Representatives,50 6 appointments made by the President pro tempore of the
U.S. Senate,51 and 6 appointments made by the Secretary. These appointments will serve
staggered terms, with the initial appointments made by the Secretary to serve for three years, the
initial appointments made by the House to serve four years, and the initial appointments made by
the Senate to serve six years. All subsequent appointments will serve six years.52
Mission
NACIQI advises the Secretary on matters related to accreditation and to the eligibility and
certification process for institutions of higher education. Specifically, NACIQI provides
recommendations to the Secretary regarding
48 These 32 accrediting agencies do not include the 8 accrediting agencies that have not undergone a recognition review
since the new distance education and correspondence education regulations came into effect in July 2010. Thus, in
total, 40 accrediting agencies currently have distance education within their scope of recognition. For more
information, see U.S. Department of Education, “Accreditation in the United States, Accrediting Agencies Recognized
for Distance Education and Correspondence Education,” http://www2.ed.gov/admins/finaid/accred/
accreditation_pg10.html#Distance.
49 Prior to NACIQI, the National Advisory Committee on Accreditation and Institutional Eligibility assisted the
Secretary with recognition of accrediting agencies. NACIQI replaced this committee.
50 Section 114(b)(1)(B) of the HEA specifies that of the six appointments made by the Speaker of the House of
Representatives, three will be made at the recommendation of the majority leader of the House of Representatives and
three will be made at the recommendation of the minority leader of the House of Representatives.
51 Section 114(b)(1)(C) of the HEA specifies that of the six appointments made by the President pro tempore of the
Senate, three will be made at the recommendation of the majority leader of the Senate and three will be made at the
recommendation of the minority leader of the Senate.
52 The HEA authorized NACIQI through September 30, 2014. Its authorization has been extend by one year through
September 30, 2015. P.L. 113-174.
Congressional Research Service
15
An Overview of Accreditation of Higher Education in the United States
• the establishment and enforcement of criteria for recognition of accrediting
agencies or associations under Subpart 2 of Part H, Title IV, of the HEA;
• the recognition of specific accrediting agencies or associations or a specific state
approval agency;
• the preparation and publication of the list of nationally recognized accrediting
agencies and associations;
• the eligibility and certification process for IHEs under Title IV of the HEA;
• the relationship between (1) accreditation of IHEs and the certification and
eligibility of such institutions and (2) state licensing responsibilities with respect
to such institutions; and
• any other advisory functions relating to accreditation and institutional eligibility
that the Secretary may prescribe.
Process
By law, NACIQI is required to meet not less than twice a year to review applications for
recognition submitted by accrediting agencies. The usual times for the meetings are spring (May-
June) and fall (November-December).
Accrediting agencies seeking initial recognition from the Secretary and those seeking renewals of
recognition typically submit application packages to ED in advance of the next scheduled
NACIQI meeting. In preparation for the meeting, NACIQI members are provided with the
accrediting agencies’ applications and supporting documentation, any analyses performed by ED
staff, and other information. During the NACIQI meetings, accrediting agencies applying for
recognition, ED staff, and third parties who request to be heard are invited to make oral
presentations.
NACIQI conducts its business in public, and transcripts of the proceedings are made available for
public dissemination. After each meeting, recommendations offered by NACIQI concerning
recognition are forwarded to the Secretary, who makes the final determination regarding
recognition. An appeals process is available to any agency that disagrees with the
recommendation provided by NACIQI53 and to any agency that disagrees with the Secretary’s
final recognition decision.54
Current Members
In May 2010, the final appointments to NACIQI were finalized by the House. The following list
provides the names, titles, and affiliations of the current NACIQI members, by appointment
authority and term duration.
Appointments by Secretary Duncan for six-year terms include55
53 34 C.F.R. §602.34 et seq.
54 34 C.F.R. §602.38.
55 These are the second set of Secretarial appointments. The first set had three-year terms that expired in September,
(continued...)
Congressional Research Service
16
An Overview of Accreditation of Higher Education in the United States
• Sudan D. Phillips, NACIQI Chair; Provost and Vice President for Academic
Affairs, University at Albany, State University of New York;
• Simon J. Boehme, Student, Cornell University;
• Robert L. Derlin, Associate Provost, New Mexico State University at Las Cruces;
• Frank H. Wu, Chancellor and Dean, University of California, Hastings College of
Law; and
• Frederico Zaragoza, Vice Chancellor of Economic and Workforce Development,
Alamo Colleges.
Appointments made by the House for four-year terms include56
• George French, President, Miles College;
• Arthur Keiser, Chancellor, Keiser University;
• William “Brit” Kirwan, Chancellor, University System of Maryland;
• William Pepicello, President, University of Phoenix;
• Arthur Rothkopf, Senior Emeritus, Lafayette College; and
• Carolyn Williams, President Emeritus, Bronx Community College of the City
University of New York.
Appointments made by the Senate for six-year terms include57
• William Armstrong, President, Colorado Christian University;
• Jill Derby, Governance Consultant, Association of Governing Boards of Colleges
and Universities;
• Anne Neal, President, American Council of Trustees and Alumni;
• Richard O’Donnell, Chief Revenue Officer, The Fullbridge Program;
• Cameron Staples, President and CEO, New England Association of Schools and
Colleges; and
• Larry Vanderhoef, Chancellor Emeritus, University of California at Davis.
(...continued)
2013. From here on out, Secretarial appointees will serve six-year terms. These members’ terms will expire in
September 2019. The sixth secretarial appointment is in-process.
56 These members’ terms expired on September 30, 2014. Those members recommended for nomination by the speaker
of the U.S. House of Representatives, Arthur Keiser, William Pepicello, and Arthur Rothkopf, have been appointed for
another term. The status of those members recommended for nomination by the minority leader of the U.S. House of
Representatives is currently unknown. Vacancies on the committee must be filled within 90 days after the vacancy
occurs. Rep. Bachmann, “Appointment of Individuals to National Advisory Committee on Institutional Quality and
Integrity,” Congressional Record, vol. 160, part 133 (September 17, 2014), p. H7630; HEA §114(b)(5).
57 These members’ terms expire September 30, 2016.
Congressional Research Service
17
An Overview of Accreditation of Higher Education in the United States
Issues for Consideration
Among the issues that could receive consideration during the reauthorization of the HEA58 are
several issues related to the role of accreditation in determining institutional eligibility to
participate in Title IV federal student aid programs. Some issues that may receive attention
include the use of accreditation as a measure of quality, potential ways of restructuring or
streamlining the accreditation process, accreditation’s role in the changing postsecondary
education landscape, and transparency and potential conflicts of interest in the accreditation
process.
Quality Measures
Both institutional accreditation and programmatic accreditation are often viewed as measures of
the quality of education provided by an IHE. Institutional accreditation may be seen as a measure
of institutional quality, signaling that an IHE meets a set of institution-level performance
standards, while programmatic accreditation indicates that a specific program meets established
standards for a certain field of study. Whether and to what extent the federal government should
rely on these two types of accreditation as measures of educational quality are issues that may
receive attention during HEA reauthorization.
Institutional Accreditation
IHEs must be accredited by an ED-recognized accrediting agency to participate in Title IV federal
student aid programs and thus gain access to a source of revenue that is vital for many IHEs.
Institutional accreditation by an ED-recognized accrediting agency may be considered a measure
of institutional quality, because it indicates that an IHE meets performance standards delineated
by the accrediting agency and maintains financial stability, as determined by an accrediting
agency’s review.
Issues arise perennially regarding whether accreditation is a true measure of institutional quality
and what role the federal government should play in measuring or ensuring institutional quality.
Some proponents of accreditation as a measure of institutional quality believe that the
accreditation process should be refocused on student achievement or student outcome measures.
They suggest accreditation is currently too reliant on assessing inputs (e.g., the proportion of
professors with Ph.D.s or the maintenance of facilities and learning resources) and propose
incorporating student outcome metrics into the accreditation process, which could include
• graduation rates;
• retention rates;
58 Many HEA programs are authorized through FY2014. Under Section 422 of the General Education Provisions Act
(GEPA), if Congress has not passed legislation extending a program during the regular session that ends prior to the
beginning of the terminal fiscal year of the program’s authorization, the program is automatically extended for an
additional fiscal year. Since the HEA was not extended during the 2nd Session of the 112th Congress, programs for
which FY2014 was the final year of authorization were automatically extended through FY2015. Some programs in the
HEA are authorized beyond FY2014.
Congressional Research Service
18
An Overview of Accreditation of Higher Education in the United States
• job placement rates; and
• student performance in skills assessment (e.g., critical thinking and
communication).59
There is disagreement, however, as to how such metrics should be determined. Some believe that
they should be determined by individual IHEs, based on their own missions,60 while others
advocate for standard metrics to be applied to IHEs participating in the Title IV programs.61
Under either scenario, accrediting agencies could be the entity to evaluate whether the metrics
were met by an IHE. If federal standards were set, consideration might be given to what extent
the characteristics of students enrolled at an individual IHE would affect its expected performance
(e.g., for-profit IHEs and community colleges enroll a higher proportion of low-income students
who tend to have lower graduation rates) and how much discretion accrediting agencies could
have in evaluating outcomes based on such characteristics.62
Also, while this information may prove useful to the federal government in determining which
IHEs are of an acceptable quality to participate in the Title IV FSA programs and to consumers
choosing which IHE to attend, there are several potential issues relating to the collection of data
for determining whether student outcome metrics have been met. For instance, various federal
and state entities, accrediting agencies, and individual IHEs already collect data relating to
student performance. An analysis of the types of data currently collected by each of these entities
could be performed to avoid duplication of collection efforts and the potential for adding time and
costs to the accreditation process.
The creation of a federal unit record system—a longitudinal data collection system that allows for
the collection of individual students’ education records over time (i.e., throughout their education
careers and time in the workforce)—is a tool that could be used by the federal government and
accrediting agencies to aid in collecting data relating to student performance and in evaluating
institutional performance. Currently, Section 134 of the HEA specifically prohibits the
establishment of a federal unit record system. If permitted, however, such a system may be an
efficient means of tracking student progress, because comprehensive data would be accessible in
one location. Yet the collection of student outcome data necessarily involves tracking individual
students’ performance; efforts would need to be made to safeguard individual students’ privacy
during the collection, merging, and reporting of data.63 Concerns about privacy have figured
prominently in the discourse of tracking student outcomes.
Opponents of using accreditation as a measure of institutional quality believe that accreditation’s
dual role as Title IV gatekeeper and reviewer of institutional quality is inherently in conflict. They
suggest that it would be desirable to sever the link between accreditation and access to Title IV
59 Serena Golden, “How Best to Assess?,” Inside Higher Education, November 18, 2013.
60 See, for example, The Council for Higher Education Accreditation, Accreditation and Accountability: Looking Back
and Looking Ahead, Washington, DC, August 2011, p. 8.
61 U.S. President (Obama), “The President’s Plan for a Strong Middle Class & A Strong America,” Public Papers of
the Presidents of the United States, February 2013, p. 5, http://www.whitehouse.gov/sites/default/files/uploads/
sotu_2013_blueprint_embargo.pdf.
62 For an in-depth analysis of how student outcome metrics compare across institutional sectors, see U.S. Government
Accountability Office, Student Outcomes Vary at For-Profit, Nonprofit, and Public Schools, GAO-12-143, December
2011, http://www.gao.gov/assets/590/586738.pdf.
63 For supporting and opposing views of the policy option to implement a student unit record system, see Hans Peter
L'Orange and Frank J. Balz, “Two Perspectives on Student Unit Records,” Student Aid Perspectives, July 10, 2013.
Congressional Research Service
19
An Overview of Accreditation of Higher Education in the United States
funds and return accreditation to its role as a private, voluntary system of quality assurance.
Under this paradigm, the federal government might conduct separate reviews of institutions’
financial stability, administrative capabilities, and performance with regard to student outcomes.64
Programmatic Accreditation
There is often a lack of understanding by consumers about the meaning of programmatic
accreditation, as compared to other types of accreditation (i.e., regional or national). Regional and
national accreditation attests to the overall quality of institutions and their programs, in general,
and allows students at institutions to receive Title IV aid, but it does not address the quality of
individual programs with regard to specialized programmatic criteria, such as whether the
curriculum offered meets professional guidelines. Programmatic accreditation can demonstrate
that a specific educational program within an IHE meets established standards for a certain field
of study and often serves as a signal of program quality.
While programmatic accreditation is not required for Title IV eligibility, access to some
employers, acceptance to some advanced educational programs, and eligibility for professional
licensure in some states require individuals to complete a program accredited by certain
programmatic accrediting agencies. For example, a student may enroll in a program at a Title IV
participating institution that is accredited by a regional or national accrediting agency, but the
program may lack programmatic recognition from a professional body, which can result in the
benefits associated with program completion being diminished (e.g., the student may not be able
to become licensed within his or her state). Congress might consider whether it is desirable to
support attendance, via Title IV eligibility, at programs that lack professional recognition from
programmatic accrediting agencies, when such accreditation is available.
Restructure or Streamline Accreditation
The American postsecondary education landscape is broad and varied, with institutions providing
numerous educational offerings to a diverse body of students. The approximately 7,800 Title IV
participating institutions have assorted missions (e.g., research university, liberal arts college,
sub-baccalaureate certificate programs), offer differing degrees in numerous subject areas, and
serve students who range from traditional, full-time college-aged students to part-time, older
students. To participate in the Title IV programs, however, most of these varied institutions must,
in general, be accredited by one of 18 regional or national accreditation agencies. As part of HEA
reauthorization, attention may be devoted to the extent to which the current structure of
accreditation meets the needs of such differing institutions and their students and whether the
federal accreditation agency recognition process could be restructured or streamlined to help meet
those needs. These issues are explored in greater depth below.
64 See, for example, National Advisory Committee on Institutional Quality and Integrity, Report to the U.S. Secretary
of Education: Higher Education Act Reauthorization, Accreditation Policy Recommendations, April 2012, Appendix:
Alternative Draft to the NACAQI Draft Final Report, pp. 11-15. See also Hank Brown, Protecting Students and
Taxpayers: The Federal Government’s Failed Regulatory Approach and Steps for Reform, American Enterprise
Institute, September 2013, pp. 8-9 and Lindsey M. Burke and Stuart M. Butler, Accreditation: Removing the Barrier to
Higher Education Reform, The Heritage Foundation, September 21, 2012, p. 18.
Congressional Research Service
20
An Overview of Accreditation of Higher Education in the United States
Restructure the Accreditation System
Regional accrediting agencies alone accredit over 3,000 of the approximately 7,800 Title IV
participating institutions, with institutions in each region including two-year, four-year, and less-
than-two-year public, private nonprofit, and private for-profit institutions. Additionally, these
institutions have diverse missions and student populations.
The wide array of institutions served by regional accrediting agencies has led some to propose a
restructuring of the accreditation system, with accreditors focusing more narrowly on types of
institutions accredited (e.g., community colleges, research universities), rather than on institutions
that fall within a particular geographic region. By doing so, they argue, peer reviewers and
professionals familiar with the operations of each type of institution would evaluate institutions
within that category, thus ensuring a strong peer-review foundation, and help to establish better
measures of outcomes and accountability.65
Congress might consider whether restructuring the current accreditation system is desirable and,
if so, how a new structure could be fashioned. Restructuring options that Congress might consider
include
• encouraging or facilitating the transformation of the current regional
accreditation system into one organized on the basis of institutional type or
mission or
• allowing other entities, such as a state regulatory body, to serve the accreditation
agency role of determining the quality of an institution.
Streamline the Accreditation Agency Recognition Process
The process of receiving initial accreditation and then periodically having it renewed is often
viewed as time- and resource-intensive. Although the federal government does not set specific
accreditation requirements, it indirectly influences the criteria accrediting agencies review based
on the federal standards accrediting agencies must meet to be recognized by the ED. Accrediting
agencies often state that the numerous ED-recognition criteria are onerous and unnecessary,
potentially discouraging accrediting agencies from placing greater emphasis on educational rigor
and innovation.66
Congress may wish to consider whether all aspects of the federal recognition process are
necessary in determining whether an accrediting agency is a reliable authority on the quality of
the education being offered or whether other steps could be taken to reduce the costs and burdens
associated with the overall process. Some items that have been raised include
• decreasing or modifying the existing statutory and regulatory criteria for federal
recognition of accrediting agencies and
65 See, for example, U.S. Congress, House Committee on Education and the Workforce, Subcommittee on Higher
Education and Workforce Training, Keeping College Within Reach: Discussing Program Quality Through
Accreditation, Prepared Statement of Dr. Michale McComis, Executive Director, Accrediting Commission of Career
Schools and Colleges, 113th Cong., 1st sess., June 13, 2013, H.Hrg. 113-22 (Washington: GPO, 2013), pp. 17-18.
66 Judith S. Eaton, What Issues Are Critical to Consider in Advancing Quality Assurance in Higher Education?,
Council for Higher Education Accreditation, May 2014, p. 5.
Congressional Research Service
21
An Overview of Accreditation of Higher Education in the United States
• redistributing the responsibilities between accrediting agencies and ED (e.g.,
shifting more oversight of institutional financial sustainability to ED).67
The Changing Postsecondary Education Landscape
Efforts to provide access to postsecondary education to a broad variety of students (e.g., older,
working, and/or low-income students) and potentially reduce postsecondary educational costs for
students have resulted in the emergence or further proliferation of nontraditional educational
delivery models and providers. For instance, although competency-based education (CBE) has
been used by some schools for decades, recently there has been an increased interest in CBE as a
means to potentially decrease time to degree completion and, therefore, costs to students.68
Additionally, CBE and other models of online education delivery enable students to participate in
education in ways that give students the flexibility to work around time constraints and focus on
coursework when convenient. While some accrediting agencies have already begun to address
such issues in their review processes, Congress could consider whether accreditation is the best
way to address these types of educational offerings and, if so, to what extent it should do so.
Competency-Based Programs
Undergraduate educational programs at public, private nonprofit, and proprietary institutions
must meet standards pertaining to minimum amounts of instructional time to be eligible to
participate in Title IV federal student aid programs. Generally, these programs are measured in
credit hours, with one credit hour typically equaling two hours of homework for each hour of
class attendance required of a student per week.69 Historically, the amount of time a student spent
receiving instruction was seen as an indication of the quality of the education being provided (i.e.,
the more instruction time required, the more a student was expected to learn); however, ED has
explicitly stated that there is no implicit “seat time” requirement under the credit hour regulations
and that it is used only for federal program purposes, thus allowing institutions to set their own
academic standards.70 As part of the institutional accreditation process, accrediting agencies are
required to review an institution’s policies for determining credit hours but do not evaluate the
course content at IHEs.
CBE, an educational delivery model that has gained significant attention in recent years, focuses
on assessing a student’s mastery of specified learning objectives or competencies. Unlike a
traditional educational program in which students must meet a specified number of credit hours to
progress and graduate, students in CBE programs progress through a program by demonstrating
the mastery of a competency. However, for purposes of participating in the Title IV FSA
programs, institutions offering CBE programs must be able to demonstrate how the method of
67 See, for example, National Advisory Committee on Institutional Quality and Integrity, Report to the U.S. Secretary
of Education: Higher Education Act Reauthorization, Accreditation Policy Recommendations, April 2012, p. 6 and
Judith S. Eaton, “Accreditation and the Next Reauthorization of the Higher Education Act,” Inside Accreditation, vol.
9, no. 3 (June 3, 3013), http://www.chea.org/ia/IA_2013.05.31.html.
68 Paul Fain, “Competent at What?,” Inside Higher Ed, December 12, 2013.
69 For additional information on the use of the durational requirements (i.e., clock and credit hours) institutions must
meet to be eligible to participate in HEA Title IV federal student aid programs, see CRS Report R43159, Institutional
Eligibility for Participation in Title IV Student Financial Aid Programs, by Alexandra Hegji and Shannon M. Mahan.
70 U.S. Department of Education, Office of Postsecondary Education, Higher Education, “Program Integrity Questions
and Answers—Credit Hour,” CH-A4, http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/credit.html.
Congressional Research Service
22
An Overview of Accreditation of Higher Education in the United States
measuring learning equates to the credit hour (i.e., the institution must “convert” competencies
into credit hours). This framework, therefore, requires accrediting agencies to examine how the
program’s competency requirements match up to the traditional federal credit-hour requirement.
Some argue that the accreditation framework may need to shift to enable accrediting agencies to
better evaluate actual student learning and skills acquired, rather than time spent working. For
instance, because CBE programs are not based on time spent on work, might two paths to
accreditation—a traditional path based on credit hours and a competency-based path—be
established to better serve these two differing educational approaches? Doing so may provide
agencies accrediting CBE programs with the ability to focus more attention on learning outcomes
in such programs, but may also take time to fully implement, as well-designed assessments of
learning outcomes need to be identified and/or developed.71
Accreditation agencies argue that the regulatory definition of credit hour discourages the use of
CBE because it mandates measuring programs with seat time; they recommend that accreditation
agencies be given discretion to define the relevant elements of assessing student learning.72
Additionally, the issue of whether the credit hour should be completely decoupled from the
accreditation process for CBE programs (i.e., institutions and their accrediting agencies would not
be required to equate self-paced competency completion with credit-hours) may arise.73 Such
decoupling could take place within the current accreditation framework or could be used in the
above-described two-path framework. As with the creation of a two-path framework, decoupling
credit hours from CBE programs could provide accrediting agencies with greater ability to focus
on learning outcomes, but it would take time to implement and develop well-designed
assessments of learning outcomes.
Online Education Providers and Credentials
Under current law, the Secretary may include within an accrediting agency’s scope of recognition
the ability to assess an IHE’s distance education programs, which include online education
programs. However, since enactment of the provision allowing this in 1998, the use of online
education has increased significantly and new forms of online education have developed.74
71 Paul J. LeBlanc, “Accreditation in a Rapidly Changing World,” Inside Higher Ed, January 31, 2013.
72 Letter from Michale S. McComis, Executive Director, Accrediting Commission of Career Schools and Colleges, to
Susan D. Phillips, Chairperson, National Advisory Committee on Institutional Quality and Integrity, May 23, 2014,
http://www2.ed.gov/about/bdscomm/list/naciqi-dir/policy-initiatives-2014.pdf.
73 Indeed, ED regulations define a subset of CBE programs, known as direct assessment program, which provides IHEs
with an option to measure student learning based solely on competencies mastered and does not rely on credit hours at
all. The regulatory definition of direct assessment programs reads “A direct assessment program is an instructional
program that, in lieu of credit hours or clock hours as a measure of student learning, utilizes direct assessment of
student learning, ... [which means] a measure by the institution of what a student knows and can do ... ” However, the
regulation then requires that an IHE offering a direct assessment program must “establish a methodology to reasonably
equate the direct assessment program ... to [credit hours].” 34 C.F.R. §668.10(a). Many believe this new definition of
direct assessment is a step closer to decoupling competency-based programs from the credit hour; however, guidance
issued by ED following the enactment of the direct assessment regulation caused confusion among IHEs. In response to
a report from ED’s Office of Inspector General, ED’s Office of Postsecondary Education has agreed to publish
additional guidance on the differences between CBE programs and direct assessment programs.
74 I. Elaine Allen and Jeff Seaman, Grade Change: Tracking Online Education in the United States, Babson Survey
Research Group, January, 2014, p. 15.
Congressional Research Service
23
An Overview of Accreditation of Higher Education in the United States
One such new form is massive open online courses (MOOCs), which are typically free or low-
cost online versions of college courses available to individuals outside of an institution’s regular
student body, and usually no credits are awarded for class completion. Although the initial view
of MOOCs as potential higher education “game changers” has been muted, MOOC-type offerings
still remain viable options for the delivery of postsecondary education.75 For instance, some IHEs
are integrating MOOCs into their course offerings in various ways, including
• offering “flipped classrooms,” in which students learn content online at home and
then complete assignments in class with faculty support and feedback;
• offering “blended learning,” in which courses are taught in a traditional
classroom setting but also incorporate online components; or
• providing supplementary materials for students.
Alternatively, some providers of MOOC-type offerings give students the opportunity to receive
certificates of completion or “badges” that signify their mastery of a skill for a fee. Mastery of a
skill can be illustrated in a number of ways, such as the passing of an exam, completing a project,
or attending classes. Some IHEs have begun exploring whether to award transfer of credit for
obtaining badges and some employers may consider them when determining whether to employ
an individual.76
While many of these offerings are currently free-of-charge or incorporated into traditional classes,
with some providers there may be fees associated with assessment to certify the mastery of a
skill. For instance, providers may charge students a fee for certification of course completion or
IHEs may charge students a fee for assessing a course before allowing them to transfer credits.
Such charges are currently ineligible for coverage with Title IV aid.
Such innovative approaches to delivering a postsecondary education are promising, because they
may provide more students with more convenient and lower cost access to postsecondary
educational offerings. As such, Congress may be asked to consider whether such programs are
prudent investments for federal student aid funds. In doing so, issues of how to delineate
accreditation’s role in determining the quality of such new educational options might be
addressed. For example, different levels of accreditation (e.g., institutional- or course-level
assessment) may be needed to evaluate these offerings. Evaluating individual credentials, rather
than entire institutions or degrees, may serve as a signal to employers that a student has a very
specific skill that the employer may desire, rather than a broader skill set encompassed by an
entire degree but that may not include the specific, employer-sought skill. Creating such a
bifurcated system, however, may require an assessment of whether currently recognized
accrediting agencies or other entities, such as professional organizations, are the appropriate
bodies for reviewing these offerings.
75 For a more detailed discussion on the evolution of MOOCs and their potential uses in postsecondary education, see
Andrew P. Kelly, Disruptor, Distractor, or What? A Policymakers Guide to Massive Open Online Courses (MOOCs),
Bellwether Education Partners, May 2014.
76 Fiona M. Hollands and Devayani Tirthali, MOOCs: Expectations and Reality, Center for Benefit-Cost Studies of
Education, Teachers College, Columbia University, May 2014, p. 49.
Congressional Research Service
24
An Overview of Accreditation of Higher Education in the United States
Other Potential Considerations
Congress may consider whether to implement other changes to the current accreditation
framework, including reforms to address accrediting agencies’ transparency and potential
conflict-of-interest issues.
Transparency
Currently, ED-recognized accrediting agencies must make publicly available basic information
about an IHE’s accreditation status. They must also make available to the Secretary, the relevant
state licensing or authorizing agency, and the public, upon request, a summary of an accreditation
review leading to a final accreditation decision involving the denial, termination, or suspension of
accreditation.77 Other documents pertaining to the accreditation process may remain private and
their release to external parties is often at the discretion of the accrediting agency or IHE.
Individuals, including industry participants, argue that more detailed information (e.g., reasons
for why accreditation decisions were made, IHEs’ self-studies) should be provided to potential
consumers to enable them to make well-informed decisions.78 Such additional information, they
assert, could increase public accountability and allow external stakeholders (e.g., potential and
current students) to make better informed decisions as to whether funds should be spent at a
particular IHE.79 There are concerns, however, that requiring additional information to be made
available may hinder the private and candid discussions between accrediting agencies and
institutions. While additional information may be useful, some argue, decision-makers must be
wary of encumbering the candor that is inherent in the peer review-based accreditation process.80
Conflicts of Interest
The foundation of accreditation is the peer-review process, in which the majority of members of
the accrediting commissions or boards that make judgments about accreditation status are
institutional faculty and administrators. Some view the idea of colleagues reviewing colleagues in
accreditation evaluations as a weakness, citing the potential for conflicts of interest81 in a process
77 HEA §496(a)(8).
78 Many regional accrediting agencies have already taken the step of providing information relating to accreditation
decisions beyond that which is federally required. For instance, the Western Association of Schools and Colleges,
Accrediting Commission for Community and Junior Colleges, now requires member institutions to post their self-
evaluations, evaluation team reports, and Commission action letters on their websites. See, for example, U.S. Congress,
House Committee on Education and the Workforce, Subcommittee on Higher Education and Workforce Training,
Keeping College Within Reach: Discussing Program Quality Through Accreditation, 113th Cong., 1st sess., June 13,
2013, H.Hrg. 113-22 (Washington: GPO, 2013), pp. 11-12.
79 Letter from Darla Spence Coffey, President and Chief Executive Officer, Council on Social Work Education and Jo
Ann R. Coe Regan, Director, Office of Social Work Administration, Council on Social Work Education, to Carol
Griffiths, National Advisory Committee on Institutional Quality and Integrity, May 30, 2014, http://www2.ed.gov/
about/bdscomm/list/naciqi-dir/policy-initiatives-2014.pdf.
80 See, for example, U.S. Congress, Senate Committee on Health, Education, Labor, and Pensions, Accreditation as
Quality Assurance: Meeting the Needs of 21st Century Learning, Statement of Dr. Arthur Levine, President of the
Woodrow Wilson National Fellowship Foundation, 113th Cong., 2nd sess., December 12, 2013, p. 3.
81 Currently, most accrediting organizations are comprised of and funded by the institutions they accredit or function as
extensions of professional bodies.
Congressional Research Service
25
An Overview of Accreditation of Higher Education in the United States
that essentially serves a gate-keeping role for access to billions of dollars in federal student aid.82
Others, however, claim that such a review helps accentuate the difference between genuine
quality review by industry experts and bureaucratic scrutiny for compliance, while pointing to the
major role peer review plays in government and other nongovernment organizations in research,
medicine, and other sciences.83 To address these concerns, Congress could explore whether a
different methodology for institutional review is proper and to what extent peers may be involved
in that evaluation.
Author Contact Information
Alexandra Hegji
Analyst in Social Policy
adhegji@crs.loc.gov , 7-8384
82 See, for example, U.S. Congress, House Committee on Education and the Workforce, Subcommittee on Higher
Education and Workforce Training, Keeping College Within Reach: Discussing Program Quality Through
Accreditation, Statement of Anne D. Neal, President, American Council of Trustees and Alumni, 113th Cong., 1st sess.,
June 13, 2013, H.Hrg. 113-22 (Washington: GPO, 2013), p. 19.
83 Judith S. Eaton, “Accreditation 2.0,” Inside Higher Ed, January 18, 2010.
Congressional Research Service
26